THE BACT ANALYSIS GUIDE

After identifying all of the control technologies with the practical potential for application to the emission unit, the BACT Analysis proceeds with eliminating technically infeasible control scenarios. For the purposes of a BACT Analysis, a technically feasible control scenario is one that has been used in the “real world”. By this I mean that just because a professor at some university has developed an experimental device for controlling NOx from a biomass boiler doesn’t mean you have to consider it as a technically feasible control device in your BACT Analysis. However, if a control device is commercially available and has the practical potential to control emissions from your source, then you must consider it to be technically feasible and include it in your BACT Analysis.

According to the 1990 EPA NSR Workshop Manual, in order to show that a control scenario is technically infeasible you must “clearly document and show, based on chemical, physical, and engineering principles, that technical difficulties would preclude the successful use of the control option on the emission unit under review”.

Here is an example:

Our client wanted to install a 6-MW Biomass Boiler to supply process heat for the greenhouses at their facility. Because of the potential emissions from the proposed emission unit, our client was required to perform a BACT Analysis for PM, PM10, NOx, and CO.

One of the control devices identified for the control of particulate matter (PM and PM10) from the boiler was a fabric filter, also known as a baghouse. Although baghouses are used to control particulate emissions from biomass boilers, they are typically installed on larger units at facilities which have full-time boiler staff (1). If left unmonitored, burning cinders, temperature excursions, and/or operating upsets could result in a fire (2). Our client did not have a full-time boiler staff and therefore using a baghouse to control particulates from the proposed boiler was deemed technically infeasible.

If you have questions regarding the technical feasibility of the control technologies that you have identified, feel free to contact Brandon Mogan at 800-850-2348 ext. 6115, or click here for more information.

(1) Resource Systems Group, Inc.
(2) Hog Fuel Boiler RACT Determination. Washington State Department of Ecology. Doc. No. 03-02-009

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• Control Devices
• Alternative source operating scenarios
• Alternative fuel combustion techniques
• Control technologies that have been applied to similar emission units

The list of potentially applicable control technologies should be comprehensive. It should include every control scenario from that which provides the most pollutant control (typically LAER) to that which provides the least pollutant control. When generating this list, one must consider all sources of information, including but not limited to:

• EPA’s RACT/BACT/LAER Clearinghouse
• EPA/State air quality permits
• Federal/State air emission inventories
• Control equipment vendors
• Manufacturer’s and trade associations
• International and foreign environmental agencies
• Inspection/Performance test reports
• Technical papers and journals
• Pollution prevention resources

The process of identifying applicable control technologies is a tedious and in-depth process. There are, however, some on-line resources available that offer a good starting point for this purpose. The following is a review of some more commonly referenced sources for identifying control technologies.

EPA’s RACT/BACT/LAER Clearinghouse

The Environmental Protection Agency’s (EPA’s) RACT/BACT/LAER Clearinghouse (RBLC) is a database of best available control technologies that have been applied to reduce emissions of air pollutants. As seen below, it is set up in a very user friendly fasion:

RBLC Database Search

This image is of a “find lowest emission rate” search for carbon monoxide (CO) emissions from a commercial size wood-fired boiler. This search results in the following results:

RBLC Database Search

From this search we have identified two different facilities which have applied best available control technologies for carbon monoxide emissions from their wood-fired boilers. To get more information about the type of control technology, the user must simply click on the “create report” button.

From project experience, I have found that the RBLC is very incomplete and limiting your search to control technologies found in the RBLC is not acceptable to most regulators.

South Coast Air Quality Management District (SCAQMD)

The South Coast Air Quality Management District (SCAQMD) of southern California posts their BACT decisions online and is a good resource to use to identify control technologies applicable to the emission unit, or similar emission units. Simply follow the above link to their website and search through the BACT decisions.

SCAQMD BACT Database Search Result

In this example, the emission unit (or process) is a system for manufacturing fiber-impregnated material. The control technology that was considered BACT in this case was a baghouse for the control of particulate emissions from the process coupled with the use of zero-VOC materials.

Bay Area Air Quality Management District (BAAQMD)

BAAQMD BACT Workbook Search Result

The identification of applicable control technologies is often a difficult and time consuming task. The reason for this is that, in many cases, the expectations of the regulator go beyond simple online database and resource searches. If you are required to perform a BACT Analysis, I suggest you discuss available resources with your permitting engineer because in most cases they will be the one accepting or denying your analysis.

If you would like assistance with completing your BACT Analysis, I have the project experience and proprietary tools that make the process as quick and seamless as possible. Please feel free to contact me at any time for a FREE BACT Analysis Consultation.

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